Illinois: Ownership and Oversight
Strict CPOM (Medical Corporation Act). Every owner, officer, and director of a medical corporation must be a Medical Practice Act licensee, with no minority carve-out. The definitional surprise is who that term actually includes.
Who the statute actually covers
- "Medical Practice Act of 1987 licensee" (225 ILCS 60): the Act licenses two classes: (1) physicians licensed to practice medicine in all its branches (MD and DO), and (2) chiropractic physicians (DC). So an Illinois medical corporation may lawfully have chiropractic-physician owners, while PAs and APRNs are categorically excluded.
- "Full practice authority APRN" (225 ILCS 65/65-43): an APRN who completes at least 250 hours of continuing education and 4,000 hours of supervised clinical experience after national certification, then files a notarized attestation with IDFPR.
- "Full-time equivalent" (225 ILCS 95/7): 40 hours per week per individual, the unit for the collaboration cap.
1. Who can own what
| Entity / Path | Who may own | Key limits |
|---|---|---|
| Medical Corporation (S.C.) | ALL shareholders, officers, and directors must be Medical Practice Act licensees (MD, DO, or chiropractic physician). No unlicensed person may have any part in ownership, management, or control (805 ILCS 15/13). | IDFPR registration; separate registration per Illinois location and per assumed name. |
| Professional Service Corp / PLLC | Licensees within one category of professional service or IDFPR-recognized related professions. | Confirm the related-professions categories by rule. |
| PA path | No ownership of a medical corporation. | Collaboration requirement follows the PA regardless of entity. |
| APRN path | No ownership of a medical corporation. APRNs may organize nursing-category entities; FPA-APRNs can operate them without a written collaborative agreement. | FPA changes scope and collaboration, never medical-corporation ownership. |
| Lay / MSO | Not permitted in the professional entity. | MSO under FMV MSA; keep control, proxies, and stock pledges out of the documents. |
2. Collaborative and supervisory oversight
| Role | Agreement required | Oversight mechanics | Path to independence |
|---|---|---|---|
| PA | Written collaborative agreement (225 ILCS 95/7.5); notice filed with IDFPR, plus notice of delegated prescriptive authority for controlled substances. Schedule II delegation requires 45 graduate pharmacology contact hours. | A collaborating physician may collaborate with a maximum of 7 FTE PAs (225 ILCS 95/7), with exceptions for HPSA-shortage areas. PAs in hospitals, hospital affiliates, ASTCs, and FQHCs are exempt from both the written agreement and the ratio; they practice on clinical privileges (95/7.7). | None. |
| APRN | Written collaborative agreement with a physician (225 ILCS 65/65-35). Same hospital/ASTC privileges alternative in facility settings. | Parallel 7 FTE cap under MPA § 54.5. Controlled substance delegation requires filed notice. | Yes: FPA-APRN status under 225 ILCS 65/65-43 (250 CE hours + 4,000 clinical hours + attestation) removes the written collaborative agreement. Retains limited consultation for benzodiazepines and Schedule II narcotics. |
3. Primary authorities
- 805 ILCS 15 (Medical Corporation Act); 805 ILCS 10 (Professional Service Corporation Act).
- 225 ILCS 60 (Medical Practice Act of 1987).
- 225 ILCS 95/7, 7.5, 7.7.
- 225 ILCS 65/65-35, 65-43.
Practical read: When someone says "Illinois medical corp owners must be Medical Practice Act licensees," make them finish the sentence: that means MD, DO, or chiropractic physician, and nobody else. Illinois runs two parallel systems: office practices under written agreements and the 7 FTE cap, and hospital/ASTC/FQHC practices on clinical privileges with no agreement at all.
General education, not legal advice.